Epstein Secrets

C 2028 Harrison Street, Suite 202 Hollywood, Florida 33020 Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 Attorneys for Jane Doe # I and Jane Doe # 2 16 EFTA00100353 Case 9:08-cv-80736-KAM Document 205-2 Entered on FLSD Docket 07/05/2013

f the Non-Prosecution Agreement that was entered into between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida ("USAO-SDFL"). See, e.g., DE 99 at 6 (recognizing that the relief Petitioners seek "is to invalidate the non-prosecution agreement"). But even assuming arguendo

Lauderdale Florida 33301 Telephone Facsimile E-mail: and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah Salt Lake City, UT 84112 Telephone: Facsimile: E-Mail: Attorneys for Jane Doe #1 and Jane Doe #2 17 EFTA00208606 Case 9:08-cv-80736-KAM Document 226 Entered

.' As a fourth and final illustration, the victims requested information about why the U.S. Attorney's Office for the Southern District of Florida (USAO-SDFL) was "conflicted out" of considering issues relating to the Epstein matter, as well as any information that developed about that conflict after the

llywood, Florida 33020 (954) 414-8033 Fax: (954) 924-1530 Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 E-mail: [email protected] Attorneys for Jane Doe # 1 and Jane Doe # 2 16 EFTA00799490 Case

f the Non-Prosecution Agreement that was entered into between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida ("USAO-SDFL"). See, e.g., DE 99 at 6 (recognizing that the relief Petitioners seek "is to invalidate the non-prosecution agreement"). But even assuming arguendo

4-2820 Fax: (954) 524-2822 E-mail: [email protected] Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 E-mai . [email protected] Attorneys for Jane Doe # 1 and Jane Doe # 2 36 EFTA00799530 Case

have limited the USAO-SDFL' s capacity to prosecute Epstein in the Southern District of Florida for his federal offenses against Petitioners,17 the USAO-SDFL did not bargain away the possibility of federal criminal charges being instituted in other districts based on the alleged sexual acts that Epstein c

-2820 Fax: (954) 524-2822 E-mail: [email protected] Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 E-mat . casserp-glaw.utah.edu Attorneys for Jane Doe # 1 and Jane Doe # 2 36 EFTA00081051 Case

have limited the USAO-SDFL's capacity to prosecute Epstein in the Southern District of Florida for his federal offenses against Petitioners,17 the USAO-SDFL did not bargain away the possibility of federal criminal charges being instituted in other districts based on the alleged sexual acts that Epstein c

derdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 Attorneys for Jane Doe # 1 and Jane Doe # 2 Respondent's Exhibit B Case No. 08.80736-CIV-MARRA E

to the instant matter. This litigation involves petitioners' claims that the United States Attorney's Office for the Southern District of Florida (USAO-SDFL) violated the petitioners' rights under the Crime Victims Rights Act (CVRA) when the USAO-SDFL entered into a non-prosecution agreement with Jeffrey

on FLSD Docket 08/16/2013 Page 38 of 64 and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: [email protected] Attorneys for Jane Doe #1 and Jane Doe #2 CERTIFICATE OF

d.6 As a fourth and final illustration, the victims requested information about why the U.S. Attorney's Office for the Southern District of Florida (USAO-SDFL) was "conflicted out" of considering issues relating to the Epstein matter, as well as any information that developed about that conflict after the

(800) 400-1098 E-Mail: [email protected] Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah* 383 S. University St. Salt Lake City, UT 84112 Telephone: (801) 585-5202 E-Mail: cassellpfalaw.utah.edu This daytime business address is provided for identification and correspondence

to the Illegal Concealment of the Non- Prosecution Agreement 10 2. Evidence Exists that the Epstein Defense Team Acted in Bad Faith. 18 3. The USAO-SDFL Was Not Authorized to Extend Epstein Immunity Without First Conferring with his Victims. 23 II. THE CVRA AUTHORIZES RESCISSION AS A REMEDY.